OCC Bulletin 2025-37 lets examiners carry forward prior conclusions on the Training and BSA Officer pillars for community banks, under strict conditions and never for two consecutive exams. Here is what it does and does not change.
OCC Bulletin 2025-37, issued November 24, 2025, applies to community bank examinations beginning February 1, 2026
Examiners may carry forward prior conclusions for the Training and BSA Officer pillars only, at their discretion
Findings may not be carried forward for two consecutive examinations
Conditions include satisfactory prior findings, no material changes to risk profile, staffing, or operations, no material findings from independent testing, and no adverse findings in the current exam
Examiners may rely on independent testing they consider adequate, section by section, depending on the quality of the work
What a Real AML Program Review Should Include
What a proper program review should evaluate, including the independent testing examiners may rely on.
How to Perform an AML Risk Assessment in 2026
The OCC expects a well-documented, current risk assessment to earn examination credit. Here is the step-by-step framework.
What Happens After a Bad AML Program Review: A Recovery Checklist
A structured way to work through program gaps before your next examination.
Tags
AML/BSA Compliance Insights Team · Soflo Consulting
Soflo Consulting Team publishes BSA/AML compliance analysis for regulated businesses across the United States. The team covers regulatory enforcement actions, FinCEN guidance, risk assessment, and emerging compliance obligations for banks, money services businesses, mortgage lenders, fintechs, and other covered institutions.
5 sections
Key Takeaways
- 1OCC Bulletin 2025-37, issued November 24, 2025, applies to community bank examinations beginning February 1, 2026
- 2Examiners may carry forward prior conclusions for the Training and BSA Officer pillars only, at their discretion
- 3Findings may not be carried forward for two consecutive examinations
- 4Conditions include satisfactory prior findings, no material changes to risk profile, staffing, or operations, no material findings from independent testing, and no adverse findings in the current exam
- 5Examiners may rely on independent testing they consider adequate, section by section, depending on the quality of the work
Need Expert Guidance?
Put these insights into action. Talk to a compliance professional at Soflo Consulting compliance specialist.
Stay Ahead of Compliance
Get FinCEN updates, BSA/AML guidance, and federal compliance news delivered to your inbox - no fluff.
